There were three noteworthy regulatory and compliance updates for banks and credit unions in July of 2023. Below are the details on these changes and how they affect you and your institution.

IRS Delays New Payout for Inherited Retirement Accounts and Extends Rollover Period for Mistaken Payouts in 2023
The IRS issued Notice 2023-54 and delayed the implementation of the Proposed Regulations that were released in February 2022 regarding mandatory distributions for non-spouse beneficiaries. Additionally, the required minimum distribution age and Required Beginning Date is discussed.
Why Is This Important to Me?
This additional delay has caused more confusion around already complex payout rules for non-spouse beneficiaries. There is also confusion around the start date and Required Beginning Date for the RMDs for those 73 and older, as well as what to do if a client has already taken an RMD in error. OnCourse Learning has quickly created a webinar to assist you in navigating through this confusion: IRA Update (IRS Notice 2023-54): Required Minimum Distribution for Owners and Beneficiaries.
Senior Deputy Comptroller for Large Bank Supervision Testifies on Climate-Related Financial Risks
Office of the Comptroller of the Currency (OCC) Senior Deputy Comptroller for Large Bank Supervision Greg Coleman today testified before the U.S. House of Representatives’ Committee on Financial Services’ Subcommittee on Financial Institutions and Monetary Policy on the agency’s supervision of climate-related financial risks. In his testimony, Mr. Coleman discussed the OCC’s supervision activities at banks over $100 billion in consolidated assets to understand their climate-related financial risks. Mr. Coleman described the agency’s focus on climate-related financial risks as firmly rooted in its safety and soundness mandate and shared initial observations of large banks’ management of climate-related financial risks.
Why Is This Important to Me?
Climate change will likely be a prominent topic of discussion with the agencies through the rest of 2023 and into 2024. We have a webinar that discusses the impact of climate on the safety and soundness of the financial system: The ABCs of ESG: A Primer for Banks.
SEC Proposes Rule Amendments to the Broker-Dealer Customer Protection Rule
The Securities and Exchange Commission today proposed amendments to Rule 15c3-3 (the Customer Protection Rule) to require certain broker-dealers to increase the frequency with which they perform computations of the net cash they owe to customers and other broker-dealers (known as PAB account holders) from weekly to daily. Net cash owed to customers and PAB account holders must be held in a special reserve bank account. By reducing the time frame between computations, the proposal would assist broker-dealers in more dynamically matching the net amount of cash owed to customers and PAB account holders with the amount on deposit in the broker-dealer’s customer and PAB reserve bank accounts. The daily customer and PAB reserve computations would safeguard customers and PAB account holders by lessening the potential for large mismatches to build over time, thereby increasing the likelihood that they are made whole even if a broker-dealer fails. Comments will be accepted for 30 days following publication in the Federal Register, or through September 11, 2023, whichever is later.
Why Is This Important to Me?
As a note, these amendments are only in the proposal stage, so no changes to OnCourse Learning’s Bank Broker-Dealer courseware need to be changed at this time.

About the Author
Rachel Davis
Product Manager at OnCourse Learning
Rachel Davis is the Product Manager of GRC and professional education for banks, credit unions, and non-bank financial services at OnCourse Learning. Rachel has worked in the financial services industry for 12 years and keeps up to date on financial industry hot topics. Rachel received her Bachelor of Arts in English Literature from Saint Louis University.

About the Author
Rachel Davis
Product Manager at OnCourse Learning
Rachel Davis is the Product Manager of GRC and professional education for banks, credit unions, and non-bank financial services at OnCourse Learning. Rachel has worked in the financial services industry for 12 years and keeps up to date on financial industry hot topics. Rachel received her Bachelor of Arts in English Literature from Saint Louis University.